Job Safety Analysis: Illicit Discharge Investigation

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Step Potential Hazard Control
Receive report and assess initial information Unknown chemical hazards, insufficient details, unsafe site conditions Gather all available information; notify supervisor; respond with proper PPE; bring test kits or detection tools
Arrive at scene and perform initial safety assessment Traffic exposure, hostile property owners, hazardous fumes, unstable ground near ditches Park truck safely; activate beacons; set cones; use lookout if roadside; visually inspect area from a distance before approaching
Don required PPE Exposure to chemicals, contaminated water, biological hazards Wear gloves, safety glasses, high visibility vest, and other PPE based on suspected discharge
Identify the discharge location Steep banks, slippery conditions, wildlife, unknown substances Approach slowly; maintain footing; avoid touching discharge; keep distance if fumes or sheen are present
Evaluate type of discharge Chemical exposure, corrosive liquids, sewage contamination, petroleum vapors Use pH paper, odor assessment, temperature, and visual clues cautiously; never inhale fumes intentionally; take photos from safe distance
Establish exclusion zone Public entering hazardous area, crew exposure to contaminated materials Place cones or tape around site; limit entry to essential personnel only
Collect samples (if trained and required) Contact with contaminated materials, spills, splashing Use sample bottles; avoid overfilling; keep bottles at arm’s length; wear chemical resistant gloves; follow chain of custody if required
Check for upstream or downstream effects Slips in waterway, contact with contaminated sediments Walk banks carefully; probe soft areas; avoid stepping into unknown water; document visible impacts
Document findings Standing in traffic, distraction, loss of awareness Stand in safe area; use lookout if roadside; take photos and notes without entering hazardous zones
Communicate with other agencies Miscommunication or delayed response Contact stormwater coordinator, sewer department, fire department, or health department as appropriate; follow local MS4 protocol
Determine containment needs Spread of contamination, contact with flowing water Use absorbent booms if trained; never apply chemicals; coordinate with appropriate response agency before attempting containment
Leave site safely Contaminated boots or tools, traffic hazards Check for contamination on boots or clothing; decontaminate tools; remove cones and signage in reverse order
Complete report and follow up Incomplete documentation, missed hazards Fill out required illicit discharge investigation form; upload photos; provide findings to stormwater coordinator; schedule follow up site visit if needed

Suggested Personal Protective Equipment

  • Hard hat when working near roadways

  • High visibility vest or jacket

  • Safety glasses

  • Nitrile or chemical resistant gloves

  • Steel toe boots

  • Long pants and long sleeves

  • Respirator if strong fumes or unknown substances are present

  • Waterproof boots when near ditches or outfalls

Always have a complete, well-stocked first aid kit available.

JSA Category: Stormwater, Drainage, and Waterways

* The steps, hazards, and controls displayed above may be incomplete or not suit your department's needs. All job safety analyses should be a completed with frontline worker input to ensure that each potential hazard is identified and mitigated.

Please read about The Essentials Elements of a Solid Job Safety Anaylsis here.

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Job Safety Analysis
Step Potential Hazard Control
Receive report and assess initial information Unknown chemical hazards, insufficient details, unsafe site conditions Gather all available information; notify supervisor; respond with proper PPE; bring test kits or detection tools
Arrive at scene and perform initial safety assessment Traffic exposure, hostile property owners, hazardous fumes, unstable ground near ditches Park truck safely; activate beacons; set cones; use lookout if roadside; visually inspect area from a distance before approaching
Don required PPE Exposure to chemicals, contaminated water, biological hazards Wear gloves, safety glasses, high visibility vest, and other PPE based on suspected discharge
Identify the discharge location Steep banks, slippery conditions, wildlife, unknown substances Approach slowly; maintain footing; avoid touching discharge; keep distance if fumes or sheen are present
Evaluate type of discharge Chemical exposure, corrosive liquids, sewage contamination, petroleum vapors Use pH paper, odor assessment, temperature, and visual clues cautiously; never inhale fumes intentionally; take photos from safe distance
Establish exclusion zone Public entering hazardous area, crew exposure to contaminated materials Place cones or tape around site; limit entry to essential personnel only
Collect samples (if trained and required) Contact with contaminated materials, spills, splashing Use sample bottles; avoid overfilling; keep bottles at arm’s length; wear chemical resistant gloves; follow chain of custody if required
Check for upstream or downstream effects Slips in waterway, contact with contaminated sediments Walk banks carefully; probe soft areas; avoid stepping into unknown water; document visible impacts
Document findings Standing in traffic, distraction, loss of awareness Stand in safe area; use lookout if roadside; take photos and notes without entering hazardous zones
Communicate with other agencies Miscommunication or delayed response Contact stormwater coordinator, sewer department, fire department, or health department as appropriate; follow local MS4 protocol
Determine containment needs Spread of contamination, contact with flowing water Use absorbent booms if trained; never apply chemicals; coordinate with appropriate response agency before attempting containment
Leave site safely Contaminated boots or tools, traffic hazards Check for contamination on boots or clothing; decontaminate tools; remove cones and signage in reverse order
Complete report and follow up Incomplete documentation, missed hazards Fill out required illicit discharge investigation form; upload photos; provide findings to stormwater coordinator; schedule follow up site visit if needed
Suggested Personal Protective Equipment